Since the passage of Kentucky's new DTC law last summer, we have all been eagerly awaiting the day when wineries can begin shipping to Kentucky consumers. While applications are now being accepted and some licenses have been issued, early applicants have hit a couple of unexpected speed bumps. CSA and The Digest team have been talking with Kentucky officials and with our hardworking colleagues at the Wine Institute in an effort to pave a smoother road for those who come later.

What are the speed bumps? 

1. Proof of legal possession of premises. The DTC application requires a lease or deed proving that the applicant has control over the licensed premises. This is an issue for AP wineries: They do not have a lease; their occupancy is documented by an AP agreement -- and the KY ABC has rejected AP agreements submitted with applications. Stay tuned; the Wine Institute is now working to resolve the issue.

2. Product registration. Although it has not been widely publicized, product registration IS one of the requirements for KY shipper licensees. When we attempted to fulfill the requirement on behalf of our clients, we learned to our surprise that KY's online registration handles supplier licensees only. As we write this update, their system does not yet handle DTC product registrations.

We will keep people updated as the state continues to work out these issues so wineries can ship DTC into Kentucky. Stay tuned!